Ceglia v. Zuckerberg et al

Filing 128

MOTION to Compel by Facebook, Inc., Mark Elliot Zuckerberg.(Snyder, Orin)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
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:
PAUL D. CEGLIA,
:
:
Plaintiff,
:
:
v.
:
:
MARK ELLIOT ZUCKERBERG and
:
FACEBOOK, INC.,
:
:
Defendants.
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NOTICE OF ACCELERATED
MOTION TO COMPEL
Civil Action No. 1:10-cv-00569RJA

PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law, the
annexed Declaration of Alexander H. Southwell, Esq., and accompanying exhibits, the
undersigned will move this Court, as soon as the motion may be heard by this Court, to compel
Plaintiff's compliance with this Court's August 18, 2011 Order under Federal Rule of Civil
Procedure 37, and for an order directing Ceglia to comply with paragraph 5 of the Order by
furnishing forthwith his unqualified consent on the form provided by Stroz Friedberg.
PLEASE TAKE FURTHER NOTICE that, pursuant to Local Civil Rule of Procedure
7 of this Court, Defendants request oral argument and state their intention to file and serve reply
papers.

Dated:

New York, New York
September 1, 2011
Respectfully submitted,
/s/ Orin Snyder
Orin Snyder
Alexander H. Southwell
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue, 47th Floor
New York, NY 10166-0193
[phone]

Thomas H. Dupree, Jr.
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, NW
Washington, DC 20036
[phone]
Terrance P. Flynn
HARRIS BEACH PLLC
726 Exchange Street
Suite 1000
Buffalo, NY 14210
[phone]

Attorneys for Defendants Mark Zuckerberg and Facebook, Inc.

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